The Association of Certified Financial Crime Specialists is always looking for ways to enlighten the broader financial crime compliance community to trends large and small and deliver actionable guidance and intelligence that will help professionals expand their understanding of how best to detect and prevent financial crime.

In an interview with Anu, she told me her goal with this initiative was to give professionals at all levels, and even those beyond the compliance program, an easily approachable and digestible checklist of critical financial crime pain points that can both illumine individuals to better uncover a broad array of suspicious activities and pass heightened examiner scrutiny and expectations.

The list below is a summary of Anu's analysis of UK FCA fines for AML between 2002-2015 and common recurring themes identified. This list is by no means exhaustive and should not be considered as a source of regulatory requirements. Please scroll down to the end of the post for the list of fines reviewed and link to the FCA website for the original list of fines. For part one focusing on US AML fines, please click here.

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Key Observation: An interesting observation is that the key failures identified in the first fine in 2002 (earliest available on the site) are very similar in principle to those highlighted in the recent 2015 fine. Also the fines refer to ML Regulations, JMLSG Guidance and published FCA Best Practices as the references for review.

Culture of Compliance:

Failure to demonstrate the culture and level of cooperation expected by the Authority.

Senior Management Oversight (Compliance and Business):

Roles and Responsibilities: Lack of clarity re roles and responsibilities within Business and Compliance.

Failure by the Compliance officer to take reasonable steps for implementation of adequate procedures to control money laundering risk.